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One of the many factors that can cause a health insurance system to fail is “adverse selection,” a phenomenon in which those who know they will make higher-than-average claims are disproportionately likely to enroll and pay premiums. The inevitable results is a rapid increase in premiums, which encourages even more marginal consumers to forgo insurance, leaving average claims, and therefore premiums, to increase even further.

One approach to limit this problem is to limit the time frame during which enrollment is permitted. Why have limited open enrollment periods? The idea is that without them – that is, if anyone could enroll in health plans whenever they want – people could “game the system,” enrolling when they need healthcare, and disenrolling when they don't. This means that they will pay premiums (in the extreme case) only when they have high levels of claims. Obviously, this won't work for people who are worried about sudden, unexpected health problems. But a huge proportion of healthcare spending is to some extent planned, or at least anticipated, several months in advance.

When the ACA exchange system was scheduled to go into effect on January 1, 2014, the administration set the open enrollment period for federally-run exchanges to run from October 1 to December 15, 2013. This was extended to March 31, 2014, ostensibly because of technical problems at the beginning of the enrollment period.

The following year, open enrollment was scheduled to begin on November 15, 2014, and run through February 15, 2015. It was eventually extended to April 30, 2015, ostensibly because some people would discover the existence of the individual mandate penalty when preparing their income tax returns, and might want to enroll after that.

For program year 2016, enrollment opened on November 1, 2015. Direct mail, e-mail and other promotional material distributed by CMS and by insurance companies gave a deadline of December 15, 2015, for enrollment. After that deadline passed, CMS promotional material advertised that the deadline had been "extended" to January 31, 2016 – although it is unclear whether this is an extension of an enrollment period, or whether it was planned all along (the December 15 deadline begin the deadline to get coverage effective January 1, not the actual end of the open enrollment period). It remains to be seen whether the enrollment period will be extended further. Ironically, it seems more likely to be extended if enrollment is lower than desired.

The end result is that as of January 31, 2016, enrollment will have been open for 13 of the last 28 months – almost half the time. More importantly, the precedent appears to have been set that open enrollment periods will be extended frequently, if not on quite a regular schedule. While people can't depend on extensions – they are at the discretion of the administration – they have come to expect them.

The inevitable result is that the primary motivating force behind the idea of enrollment periods: “Enroll now, since you won't be able to enroll if you get sick later,” is significantly dampened.

And the end result of that is higher premiums for those who do enroll.